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#2158273 - 12/22/17 06:47 PM Account Change
ComplianceGuru89, CRCM Offline
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Joined: Sep 2015
Posts: 85
We have a special loan product that requires half of the loan amount to be secured in a special savings account and essentially held as collateral until the loan is paid off... If disclosed properly, can that savings account automatically convert into a normal savings upon payoff? Or is it possible to have just the one savings account and have an exception if they are in this program to waive fees? (regular savings has a min balance fee, and also statement fee)

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#2158278 - 12/22/17 07:34 PM Re: Account Change ComplianceGuru89, CRCM
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
You can do whatever your contract says you are going to do and what you disclose to the consumer.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2158288 - 12/22/17 08:07 PM Re: Account Change ComplianceGuru89, CRCM
ComplianceGuru89, CRCM Offline
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Joined: Sep 2015
Posts: 85
So if we disclose to the customer at account opening of the special savings account, what the fees are for a regular savings but provide a disclaimer that the fees are waived until the loan is paid off, that we don't have to re-disclose when the account is set to switch?

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